In accordance with the European Data Act (Regulation EU 2023/2854), Ledworks S.r.l. dba Twinkly provides the following mandatory information regarding its connected Twinkly smart lighting devices.
What type of data is stored?
Twinkly devices and associated app collect and process the following data types:
- Device metadata:
- MAC address ✅
- firmware version ✅
- model ✅ (internal product code)
- active LEDs ✅
- groups ✅
- mapping information ✅
- User profile:
- user email ✅
- twinkly account information ✅
- creation date and last access ✅
- user locale and region
- User-generated content
- list of light effects ✅
- custom configurations ✅
- content sharing informations ✅
The data is stored in a structured, commonly-used, machine-readable format (typically JSON). The device does not generate data continuously. The generation of data may occur in real time as a result of user interaction (e.g. via Twinkly App or voice assistants) or as a result of scheduled operations (timers or playlists).
The volume of data generated by the product, excluding content files, depends on its use and configuration (number of effects, devices, groups, etc.) and may range approximately from 1KB to 10MB.
Where is this data stored?
Depending on the type of data:
- Certain data is stored locally on your device (e.g., personal effects, downloaded effects, layouts).
- Other data may be stored on Twinkly’s secure servers to support app functionality and user account management.
Data comes directly from the device and from the Twinkly App services that enable its functionality and may be stored locally in the user's device and/or in Twinkly servers, depending on the data processed.
The retention period for user data is outlined in our Privacy Policy.
How can I view, share, or delete my data?
Users may access the data generated by their device or request its deletion submitting a request through the Twinkly Help Center.
At the user’s explicit and documented request, Twinkly will enable data sharing with a designated third party, in accordance with Article 5 of the Data Act. Sharing will only occur with user consent or upon user direction, and only for lawful, specified purposes.
On request, all available data will be provided via email in JSON format, supporting data portability and sharing.
Information about terms of use, service quality, speed, reliability, and support is available on our Twinkly Help Center.
Twinkly is the holder of trade secrets contained in the data that is accessible from the connected Twinkly devices or generated during the provision of the Twinkly App.
Users have the right to lodge a complaint alleging an infringement of any of the provisions of Chapter II of the Data Act with the competent authority designated.